Article 25 & Annex V: Packaging Format Restrictions

Top line summary

Article 25 establishes restrictions on placing certain single-use plastic packaging formats on the market. The specific formats banned are listed in Annex V. These bans apply from 1 January 2030 and cover grouped packaging, fresh produce packaging, HORECA disposables, condiment sachets, accommodation amenities, and very lightweight carrier bags.

Summary

 

📅 Key Dates

Date

Event

Priority

11 Feb 2025

PPWR enters into force

🔴 Critical

11 Feb 2027

Commission publishes Annex V guidelines with examples

🔵 Info

1 Jan 2030

Article 25 / Annex V packaging format bans apply

🔴 Critical

Color Guide: 🔴 Critical deadline | 🟠 Important milestone | 🔵 Information/Review

 

Annex V – Requirements Overview

 

🛒 Single-Use Plastic Grouped Packaging (Annex V, Point 1)

 

🔴 BANNED from 1 Jan 2030

Definition

Plastic materials used at the point of sale to bundle multiple products (bottles, cans, tins, pots, tubs, packets) to promote bulk purchasing

Examples

Shrink wrap, collation film

Exception

Packaging essential for handling purposes

 

🥬 Plastic Packaging for Fresh Produce (Annex V, Point 2)

🔴 BANNED from 1 Jan 2030

Scope

Single-use plastic packaging for unprocessed fresh fruits and vegetables weighing less than 1.5 kg

Examples

Nets, bags, trays, and containers

 

🟢 Member State Exceptions

Member States may allow exceptions if there is a demonstrated need to:

  • Prevent dehydration (e.g., maintaining produce hydration)

  • Maintain firmness or freshness (preserving texture)

  • Avoid microbiological hazards (e.g., bacterial or fungal growth)

  • Protect against physical damage during transport

  • Prevent oxidation (e.g., browning from air exposure)

  • Ensure organic produce remains separate from non-organic counterparts

 

🍽️Single-Use Plastic Packaging in HORECA Sector (Annex V, Point 3)

 

🔴 BANNED from 1 Jan 2030

Scope

Plastic packaging for food and beverages consumed on-site in hotels, restaurants, and cafes

Covered Areas

Indoor and outdoor dining areas with tables, stools, or standing spaces

Examples

Disposable trays, plates, cups, bags, and boxes

Exception

Establishments lacking access to drinking water

 

🧂 Condiment and Seasoning Packaging in HORECA (Annex V, Point 4)

 

🔴 BANNED from 1 Jan 2030

Scope

Single-use packaging for condiments, sauces, coffee creamers, sugar, and seasonings

Examples

Sachets, tubs, trays, and boxes

🟢 Exceptions

  • Provided with take-away food ready for immediate consumption

  • Individual packaging necessary for safety and hygiene in settings like hospitals or nursing homes

 

🏨 Single-Use Packaging in Accommodation Sector (Annex V, Point 5)

 

🔴 BANNED from 1 Jan 2030

Scope

Single-use packaging for personal care items provided for individual bookings in accommodation facilities

Examples

Shampoo bottles, lotion bottles, and soap sachets

Exceptions

None specified

 

🛍️ Very Lightweight Plastic Carrier Bags (Annex V, Point 6)

 

🔴 BANNED from 1 Jan 2030

Definition

Extremely lightweight plastic bags, such as those used for bulk groceries

Exception

Required for hygiene reasons OR used as primary packaging for loose food to prevent waste

 

📋 Compliance Summary Table

Packaging Category

Banned Format

Applies From

Exceptions

Grouped packaging

Shrink wrap, collation film

1 Jan 2030

Handling

Fresh produce (<1.5 kg)

Nets, bags, trays, containers

1 Jan 2030

Preservation

HORECA on-site

Trays, plates, cups, bags, boxes

1 Jan 2030

No water

Condiments (HORECA)

Sachets, tubs for sauces, sugar

1 Jan 2030

Take-away

Accommodation

Shampoo, lotion, soap sachets

1 Jan 2030

None

Lightweight bags

Thin plastic bags for groceries

1 Jan 2030

Hygiene/food

 

✓ Development Team Checklist

 

Immediate Actions

  • Audit current packaging portfolio for Annex V affected formats

  • Identify grouped packaging used at point of sale

  • Review fresh produce packaging for sub-1.5 kg items

  • Assess HORECA sector packaging for on-site consumption

  • Evaluate condiment and seasoning packaging formats

  • Review accommodation amenity packaging

  • Identify very lightweight carrier bags in use

 

Alternative Solutions

  • Evaluate reusable packaging alternatives for grouped products

  • Assess loose produce sales options

  • Source reusable tableware for HORECA partners

  • Develop refillable dispenser solutions for condiments

  • Plan wall-mounted dispenser systems for accommodation amenities

  • Evaluate paper or compostable bag alternatives

 

Timeline Actions

  • Develop transition roadmap by Q2 2026

  • Begin supplier negotiations for alternatives by Q4 2026

  • Pilot alternative solutions by Q2 2027

  • Full rollout of compliant packaging by Q2 2029

  • Ensure compliance by 1 Jan 2030 (critical deadline)

 

✓ Regulatory Team Checklist

 

Monitoring

  • Track Member State exception applications for fresh produce

  • Monitor national implementation guidelines

  • Follow Commission guidance on exception criteria

  • Track enforcement approaches across key markets

 

Verification

  • Confirm exception eligibility for specific product lines

  • Document handling necessity for grouped packaging exceptions

  • Verify hygiene justifications for lightweight bag exceptions

  • Assess take-away vs. on-site consumption classification

 

Strategic Planning

  • Map supply chain impacts of packaging format bans

  • Coordinate with HORECA and accommodation sector customers

  • Develop stakeholder communication on transition timelines

  • Prepare exception documentation where applicable

 

🔗 Legal References

Primary Regulation

  • Regulation (EU) 2025/40 – Article 22

  • Regulation (EU) 2025/40 – Annex V

 

Related PPWR Articles

Article

Relevance

Article 9

Packaging minimisation requirements

Article 21

Empty space ratio requirements

Article 26

Reuse requirements and targets

Article 29

Plastic carrier bag reduction measures

Article 32

Refill obligations for HORECA

 

Related EU Law

Legislation

Relevance

Directive (EU) 2019/904

Single-Use Plastics Directive (SUP)

Directive 94/62/EC

Previous Packaging Directive (repealed by PPWR)

Directive 2008/98/EC

Waste Framework Directive

Legal text - Law EU 40/2025

Article 25

Restrictions on use of certain packaging formats

  1. From 1 January 2030, economic operators shall not place on the market packaging in the formats and for the uses listed in Annex V.
  1. By way of derogation from Article 4(2), Member States may maintain restrictions adopted before 1 January 2025 on the placing on the market of packaging in the formats and for the uses listed in Annex V but made from materials not listed in Annex V.
  1. Paragraph 1 of this Article shall be without prejudice to Article 9(2), point (b).
  1. By way of derogation from paragraph 1 of this Article, Member States may allow micro-enterprises as defined in Recommendation 2003/361/EC as applicable on 11 February 2025 to place on the market packaging in the formats and for the uses listed in point 3 of Annex V to this Regulation where it has been demonstrated that it is not technically feasible not to use such packaging or to obtain access to infrastructure that is necessary for the functioning of a re-use system.
  1. By 12 February 2032, the Commission shall assess the positive environmental impact of the restrictions and derogations and exemptions from these restrictions, and shall take into account the availability of alternative packaging solutions that meet safety and hygiene requirements applicable to contact-sensitive packaging. On the basis of that assessment, the Commission shall, with the objective of reducing packaging waste, review this Article and Annex V to adapt them to technical and scientific progress. On the basis of that review, the Commission shall assess the appropriateness of establishing new restrictions on the use of specific packaging formats and the relevance of maintaining the derogations and exemptions set out in this Article, and, where appropriate, shall present a legislative proposal.
  1. By 12 February 2027, the Commission shall publish guidelines, in consultation with Member States and the European Food Safety Authority, which explain Annex V in more detail, including examples of the packaging formats in scope, and any exemptions from the restrictions, and provide a non-exhaustive list of fruits and vegetables that are excluded from point 2 of Annex V.
 

ANNEX V
Restrictions on use of packaging formats

Packaging format

Restricted use

Illustrative example

1. Single-use plastic grouped packaging

Single-use plastic packaging used at the point of sale to group goods sold in bottles, cans, tins, pots, tubs, and packets designed as convenience packaging to enable or encourage consumers to purchase more than one product. This excludes grouped packaging necessary to facilitate handling.

Collation films, shrink wrap

2. Single-use plastic packaging for unprocessed fresh fruit and vegetables

Single-use plastic packaging for less than 1,5 kg pre-packed fresh fruit and vegetables. Member States may set up exemptions in respect of this restriction if there is a demonstrated need to avoid water loss, or turgidity loss, microbiological hazards or physical shocks, oxidation, or if there is no other possibility to avoid commingling of organic fruits and vegetables with non-organic fruits and vegetables in compliance with requirements in Regulation (EU) 2018/848 of the European Parliament and of the Council (1) on certification or labelling, without entailing disproportionate economic and administrative costs.

Nets, bags, trays, containers

3. Single-use plastic packaging

Single-use plastic packaging for foods and beverages filled and consumed within the premises in the HORECA sector, which include all eating areas inside and outside a place of business, covered with tables and stools, standing areas, and eating areas offered to the end users jointly by several economic operators or a third party for the purpose of food and drinks consumption. Establishments in the HORECA sector that do not have access to drinking water are exempted.

Trays, disposable plates and cups, bags, boxes

4. Single-use plastic packaging for condiments, preserves, sauces, coffee creamer, sugar, and seasoning in HORECA sector

Single-use plastic packaging in the HORECA sector, containing individual portions or servings, used for condiments, preserves, sauces, coffee creamer, sugar and seasoning, except in the following cases:
(a) such packaging is provided together with take-away ready-prepared food intended for immediate consumption without the need of any further preparation;
(b) such packaging is required to ensure safety and hygiene in establishments where there is a medical requirement for individualised care, such as hospitals, clinics or nursing homes.

Sachets, tubs, trays, boxes

5. Single-use accommodation sector packaging intended for an individual booking

Single-use packaging for cosmetics, hygiene and toiletry products for the use in the accommodation sector, as described in NACE Rev. 2 – Statistical classification of economic activities, intended for an individual booking only and intended to be discarded before the next guest arrives.

Shampoo bottles, hand and body lotion bottles, sachets around bar soap

6. Very lightweight plastic carrier bags

Very lightweight plastic carrier bags, except for very lightweight plastic carrier bags required for hygiene reasons or provided as sales packaging for loose food when this helps to prevent food wastage.

Very thin bags provided for bulk groceries

(1) Regulation (EU) 2018/848 of the European Parliament and of the Council of 30 May 2018 on organic production and labelling of organic products and repealing Council Regulation (EC) No 834/2007 (OJ L 150, 14.6.2018, p. 1). 

 

Source: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, OJ L, 2025/40, 22.1.2025

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